Step up is strictly based off MSRP, not any promotion or rebate price.
The 3080Ti FTW3 Ultra has an MSRP of $1429, so step up is based on that exact amount.
The 3080ti FTW3 Ultra direct store purchase has a $130 rebate, making the price $1299. Rebates do not apply to step up, as step up can not be combined with any rebates or promotions.
Step up was meant to protect someone that purchased a product, and a new product was released within 90 days of that purchase. The 3080ti was released almost a year ago.
The EVGA Step-Up program gives you the peace of mind to purchase your product now, knowing you can upgrade to the latest parts that come out within the first 90 days from your purchase.
The program isn’t operated as advertised, since the only product that has come out in the last 90 days was the 3090ti. EVGA extends the opportunity for members to step up long after the 90 day post launch window has closed, but keeps the stipulation for MSRP in place.